This action was brought by the United States against the City of Newark, New Jersey
(hereinafter referred to as "defendant" or "City") to enforce the provisions of Title VII of the
Civil Rights Act of 1964, as amended, 42 U.S.C. § 2000e, etseq. ("Title VII"), following receipt
by the Department of Justice from the Equal Employment Opportunity Commission of charges
filed by Anthony Kerr and Kevin Rhodes, officers in the City's Police Department.

In its complaint, the United States alleges, interalia, that the defendant has violated Title
VII by (1) failing or refusing reasonably to accommodate the religious observance, practice and
belief of Mr. Rhodes, Mr. Kerr and similarly-situated present or former Muslim police officers of
wearing a beard; (2) threatening Mr. Rhodes, Mr. Kerr and similarly-situated police officers with
termination because of their religious observance, practice and belief of wearing a beard; (3)
transferring Mr. Rhodes and similarly-situated police officers to undesirable assignments because
of their religious observance, practice and belief of wearing a beard; (4) denying Mr. Kerr and
similarly-situated police officers opportunities to work special overtime events because of their
religious observance, practice and belief of wearing a beard; and (5) failing or refusing to take
appropriate action to remedy the effects of the discrimination against them. In its Answer, the
City denies these allegations.

The parties, desiring that this action be settled by appropriate consent decree and without
the burden of protracted litigation, agree to the jurisdiction of this Court over the parties, and the
subject matter of this action. Subject to the Court's approval of this Consent Decree, the parties
waive a hearing and findings of fact and conclusions of law on all issues, and further agree to the
entry of this Decree as final and binding between themselves as to the issues raised in the United
States' complaint filed in this case and the matters resolved in this Decree, pertaining to Mr.
Rhodes, Mr. Kerr, Mr. Adbul-Aziz, Mr. Mustafa, Mr. Jones, Mr. Simmons, Mr. Muhammad, Mr.
Parkman, Mr. Williams and the estate of Mr. Morrison .

This Decree, being entered with the consent of the parties, shall in no way constitute an
adjudication or finding on the merits of the case, nor be construed as an admission by the
defendant or a finding of any wrongdoing or violation of any applicable federal or state law or
regulation.

As used in this Decree, the term "date of entry of this Decree" is defined as the date on
which the Court grants final approval to and enters this Consent Decree as a final order of the
Court.

It is therefore, ORDERED, ADJUDGED AND DECREED as follows:

A. GENERAL RELIEF

1. Defendant by and through its officials, agents, employees and all persons in active
concert or participation with the defendant in the performance of employment or personnel
functions shall not engage in any act or practice that unlawfully discriminates against any
employee or potential employee with the defendant's Police Department because of that
individual's religion, as this term is defined in Title VII, including the religious observance,
practice and/or belief of wearing a beard.

2. Defendant by and through its officials, agents, employees and all persons in active
concert or participation with the defendant shall not retaliate against or in any respect adversely
affect Mr. Rhodes, Mr. Kerr or any other person because of that person's participation in or
cooperation with the initiation, investigation, litigation or administration of this case or this
Decree.

3. Defendant shall implement and use non-discriminatory employment policies
designed reasonably to accommodate the religion, as this term is defined in Title VII, of
employees in the defendant's Police Department.

4. Within thirty (30) days after the date of entry of this Decree, the City shall post
notices of the settlement of this lawsuit in the form attached hereto as Appendix A. Such notices
shall be posted in prominent and conspicuous locations used for posting notices at the Newark
Police Department. Such notices shall remain posted for a period of 90 days from the date of
execution of this Decree.

B. SPECIFIC RELIEF

Without admitting the allegations of the United States, and in settlement of the claims of
the United States for individual relief, the City agrees to offer claimants the total sum of $53,600,
which the United States has determined should be distributed, and the City has no objection in
offering to pay, as follows:

5. The City shall offer to pay Kevin Rhodes a monetary award in the amount of
$5,000, which shall be considered compensatory damages.

6. The City shall offer to pay Anthony Kerr a monetary award in the amount of
$5,900, of which $900 shall be considered back pay, plus interest, for the denial of special
overtime work in 1995 and $5,000 shall be considered compensatory damages.

7. The City shall offer to pay Farouq Abdul-Aziz a monetary award in the amount of
$5,000, which shall be considered compensatory damages.

8. The City shall offer to pay Shakoor Mustafa a monetary award in the amount of
$5,000, which shall be considered compensatory damages.

9. The City shall offer to pay Calvin Parkman a monetary award in the amount of
$5,900, of which $900 shall be considered back pay, plus interest, for the denial of special
overtime work in 1995 and $5,000 shall be considered compensatory damages.

10. The City shall offer to pay Edward Simmons a monetary award in the amount of
$5,900, of which $900 shall be considered back pay, plus interest, for the denial of special
overtime work in 1995 and $5,000 shall be considered compensatory damages.

11.The City shall offer to pay to Andrew Maurice Jonesa monetary award in the
amount of $5,900, of which $900 shall be considered back pay, plus interest, for the denial of
special overtime work in 1995 and $5,000 shall be considered compensatory damages.

12. The City shall offer to pay to the executor of the estate of Michael Morrison a
monetary award in the amount of $5,000, which shall be considered compensatory damages.

13. The City shall offer to pay to Eugene Muhammad a monetary award of $5,000,
which shall be considered compensatory damages.

14. The City shall offer to pay to Richard Williams a monetary award of $5,000, which
shall be considered compensatory damages.

15. The City shall offer to expunge from the claimants' disciplinary records any

reference to proposed or actual disciplinary action taken against Mr. Rhodes, Mr. Kerr, Mr.
Abdul-Aziz, Mr. Mustafa, Mr. Parkman, Mr. Muhammad, Mr. Simmons, Mr. Jones, Mr.
Williams, and Mr. Morrison concerning their religious observance, practice and/or belief of
wearing a beard. In order to accomplish this objective, the City shall submit to the United States,
within forty-five (45) days from its receipt of the executed Release from the claimants pursuant to
Paragraph B.17 of this Consent Decree, a copy of the claimants' disciplinary records.

16. The United States shall notify the claimants of the terms of this Consent Decree
within seven (7) days of its date of entry by mailing to each of them, by certified mail, return
receipt requested, copies of the letter in the form set forth in Appendix B and enclosing copies of
this Decree and copies of the Release in the form set forth in Appendix C. The letter identified in
Appendix B will advise the claimants that in order to accept the relief offered to them, they must
return the Appendix C Release to the defendant within thirty (30) days of their receipt of the
Appendix B letter, unless they can demonstrate good cause, to be determined by the United States,
for their failure to do so within a reasonable time thereafter.

17. In order to accept the specific relief to be offered to each of them by the City under
this Decree, Mr. Rhodes, Mr. Kerr, Mr. Abdul-Aziz, Mr. Mustafa, Mr. Parkman, Mr. Muhammad,
Mr. Simmons, Mr. Jones, Mr. Williams, and the executor of Mr. Morrison's estate must execute a
Release in the manner attached as Appendix C.

Parkman, Mr. Muhammad, Mr. Simmons, Mr. Jones, Mr. Williams, and the executor of Mr.
Morrison's estate the monetary award specified in Paragraph B of this Decree for that individual
within sixty (60) days of its receipt of that individual's executed Appendix C Release. The City
also will send to those claimants who have accepted a monetary award an IRS Form 1099 or other
appropriate form or forms with respect to those awards.

C. RECORD-KEEPING AND REPORTING

1. The City shall retain during the life of this Decree, in the City's Personnel
Department, any and all records that it generates to document the implementation of this Decree.
The City shall furnish records and documents relevant to its compliance with the implementation
of this Decree to counsel for the Department of Justice within thirty (30) days of any written
request to the defendant's attorney.

2. The United States shall have the right to inspect and copy all documents related to
disciplinary or other adverse employment action proposed or taken against Mr. Rhodes, Mr. Kerr,
Mr. Abdul-Aziz, Mr. Mustafa, Mr. Parkman, Mr. Muhammad, Mr. Simmons, Mr. Williams
during the life of this Decree upon reasonable notice to the City without further order of this
Court. Such records shall include, the following:

a. Complaint Against Personnel (C.A.P.);

b. Determination and Recommendation for Discipline form;

c. Warning Notices;

d. Preliminary Notice of Disciplinary Action;

e. Final Notice of Disciplinary Action;

f. Disciplinary Record Cards;

g. any other document prepared by the City for use in a disciplinary proceeding or other
adverse employment action.

3. The City shall retain all records that come into its possession relating to complaints or
charges of employment discrimination based on religion filed against the City with respect to the
City's Police Department or Police Department employees, agents or representatives: (a) through
the Police Department's internal grievance procedure; (b) with the United States Equal
Employment Opportunity Commission; or (c) through or with any other federal, state or local
agency authorized to receive such complaints or charges. The City shall provide copies of such
complaints or charges to counsel for the United States within twenty (20) days of its receipt of
such complaints or charges. In addition, the United States shall have the right to inspect and copy
all documents related to such complaints or charges upon reasonable notice to the City without
further order of this Court. These records shall be maintained in the City's Personnel Department.

DISPUTE RESOLUTION

The parties shall attempt to resolve informally any dispute that may occur under

this Consent Decree. The parties shall attempt to resolve any dispute in an informal manner on
their own and are not required to use a dispute resolution service. The parties shall engage in
good faith efforts to resolve the issue before seeking action by the Court. If the parties are unable
to resolve the issue within 30 days, either party may move the Court for resolution, provided that
written notice is first provided to the other party.

JURISDICTION OF THE COURT

1. During the life of this Decree, the Court shall retain jurisdiction over this Decree for the

purposes of enforcing its provisions, resolving any disputes that may arise between the parties
under it and entering such orders as may be appropriate.

2. This Decree shall terminate two (2) years from the date of its entry. Prior to its
termination any party may move, for good cause shown, to extend the duration of the Decree.

3. Each party shall bear its own costs and expenses, including attorney's fees.

On May 16, 2000, the United States filed a complaint in the United States District Court
for the District of New Jersey, against the City of Newark, New Jersey ("City") under Title VII of
the Civil Rights Act of 1964, as amended, 42 U.S.C. § 2000e, etseq. ("Title VII"), alleging that
the City had discriminated against certain employees in the City's Police Department on the basis
of their religion by failing or refusing reasonably to accommodate the employees' sincerely held
religious observance, practice and belief of wearing a beard. The City has denied the allegations
of discrimination.

This notice is being posted to announce that the United States and the City have resolved
this lawsuit by entering into a settlement agreement, called a "Consent Decree," which was
approved by the Court on ____________________, 2002.

Under the terms of the Consent Decree, the City has agreed to the following:

1. not to engage in any act or practice that has the purpose or effect of unlawfully
discriminating against any employee or potential employee with the Police
Department because of that individual's religion, as this term is defined in Title
VII..

2. not to retaliate against or in any respect adversely affect any person because that
person has opposed alleged discriminatory policies or practices by the City or
because of that person's participation in or cooperation with the initiation,
investigation, litigation or administration of this action or this Decree.

3. to implement and use nondiscriminatory employment policies designed reasonably
to accommodate the religion, as this term is defined in Title VII, of employees in
the Police Department.

4. to provide specific relief to certain individuals who were subjected to the alleged
discrimination.

5. to retain all records that come into its possession relating to complaints or charges
of employment discrimination based on religion filed against the City with respect
to its Police Department or Police Department employees, agents or
representatives: (a) through the Police Department's internal grievance procedure;
(b) with the United States Equal Employment Opportunity Commission; or (c)
through or with any other federal, state or local agency authorized to receive such
complaints.

If any employee in the City's Police Department believes that he or she has been
discriminated against in violation of Title VII, the employee should contact the U.S. Equal
Employment Opportunity Commission ("EEOC") and/or the New Jersey Department of Law and
Public Safety Division of Civil Rights ("NJDCR") about filing a charge of discrimination.

A Consent Decree has been entered settling a complaint of employment discrimination
filed by the United States against the City of Newark, New Jersey ("City") based on charges of
discrimination filed with the U.S. Equal Employment Opportunity Commission, Charge No. 171-970-396 (Kevin Rhodes) and Charge No. 171-970-408 (Anthony Kerr).

Under the terms of the Consent Decree entered on ______________, 2002, in the case of
the United States v. The City of Newark, New Jersey, Civil Action No. 00-2368 (D.N.J.), you are
being offered certain relief as settlement for your claim of employment discrimination against the
City of Newark, New Jersey.

Second, the City is offering to expunge from your disciplinary records references relating
to proposed or actual disciplinary action taken against you concerning any discipline based on
your religious observance, practice and belief of wearing a beard. In order to accomplish this
objective, the City will submit to the United States, within forty-five (45) days from its receipt of
your executed Release, a copy of your modified disciplinary record.

This relief is being offered to you on the following condition: if you accept the relief, the
City of Newark, New Jersey, will require you to release it from any and all claims you may
presently have against it arising out of this case and the two underlying EEOC charges, Charge
Nos. 171-970-396 and 171-970-408. If you decline the relief, the City of Newark, New Jersey,
will nevertheless have satisfied its obligation to the United States pursuant to the Consent Decree
in the above-captioned case and the United States will not seek additional relief on your behalf.

In order to obtain the offered relief, you must complete and return the enclosed Release.
The Release may be returned by mail or in person. If you return the Release in person, please
bring your social security card or other identification with you. You will at that time be asked to
sign the Release before a notary public. If you return the Release by mail, the Release must be
signed in the presence of a notary public and thereafter notarized before you mail it. If you return
the Release by mail, you should send it to:

If you accept the offered relief, the City of Newark, New Jersey will send you the
appropriate monetary award within sixty (60) days of its receipt of your Release. The City will
also send you an IRS Form 1099 or other appropriate form or forms with respect to this award.

IF YOU FAIL TO SUBMIT THE RELEASE, AS DIRECTED IN THIS LETTER,
WITHIN THIRTY (30) DAYS FROM YOUR RECEIPT OF THIS LETTER, YOU WILL
FORFEIT YOUR RIGHT TO ANY MONETARY OR OTHER RELIEF UNDER THE
CONSENT DECREE, UNLESS YOU CAN SHOW GOOD CAUSE, TO BE
DETERMINED BY THE UNITED STATES, FOR YOUR FAILURE TO DO SO WITHIN
A REASONABLE TIME THEREAFTER.

A copy of the Consent Decree is enclosed. If you have any questions concerning this
settlement, you may contact Abel Gomez, trial attorney for the United States Department of
Justice, at (202) 305-1582.

Enclosures

APPENDIX C

RELEASE

United States v. The City of Newark, New Jersey

State of New Jersey

}

County of _____________

}

For and in consideration of the acceptance of the relief offered to me by the City of
Newark, New Jersey pursuant to the provisions of the Consent Decree entered by the Honorable
John C. Lifland, United States District Judge, on ______________, 2002 in United States v. The
City of Newark, New Jersey, Civil Action No. 00-2368 (D.N.J.), I, [Name of Claimant], hereby
release and forever discharge the City of Newark, New Jersey, its current and future officials,
employees and agents, of and from all legal and equitable claims of employment discrimination
arising out of that action and EEOC Charge Nos. 171-970-396 and 171-970-408 which accrued
prior to _____________________, [date of entry of Consent Decree by the Court.]

I understand that the relief granted to me in consideration for this Release does not
constitute an admission by the City of Newark, New Jersey of the validity of any claim raised by
me or on my behalf.

This Release constitutes the entire agreement between the City of Newark, New Jersey and
me, without exception or exclusion.

I acknowledge that a copy of the Consent Decree in this action has been made available to
me.

I HAVE READ THIS RELEASE AND UNDERSTAND THE CONTENTS
THEREOF AND I EXECUTE THIS RELEASE OF MY OWN FREE ACT AND DEED.